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UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`BLACKBERRY CORPORATION AND BLACKBERRY LIMITED
`Petitioner
`
`v.
`
`MOBILEMEDIA IDEAS LLC
`Patent Owner
`____________
`Case IPR2013-00016 (JYC)
`Patent U.S 6,441,828.
`____________
`
`
`
`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
`PURSUANT TO 37 C.F.R. § 42.70
`
`
`
` 
`
` 
`
`

`

`
`
`Pursuant to 37 C.F.R. § 42.70, MobileMedia Ideas LLC (“Patent Owner”)
`
`hereby requests oral argument for the trial currently scheduled for October 18,
`
`2013. The Patent Owner specifies the following issues to be argued, pursuant to
`
`37 C.F.R. § 42.70(a).
`
`ISSUES TO BE ARGUED
`
`I.
`
`The Patent Owner’s Motion to Amend the Patent was filed after
`
`conferring with the Board and is compliant with the requirements of
`
`the statutes, regulations, Office Patent Trial Practice Guide, and the
`
`requests of the Board:
`
`a. the Motion to Amend explained how the proposed substitute
`
`claims 19-23 are patentable over the art of record;
`
`
`
`b. the Motion to Amend explained how the proposed substitute
`
`claims 19-23 should be construed; and
`
`c. the scope of proposed substitute claims 19-23 are narrower than
`
`the scope of the original claims.
`
`II.
`
`Proposed substitute claims 19-23 are fully supported by the patent
`
`specification and are definite.
`
`2
`
` 
`
`

`

`III. Proposed substitute claims 19-23 are patentable and patentably
`
`distinct and non-obvious over the prior art combinations relied upon
`
`by Petitioner.
`
`If any fees are due in connection with this matter, the Commissioner is
`
`hereby authorized to charge them to Attorney Deposit Account 50-3081.
`
`
`
`Date: September 9, 2013
`PROSKAUER ROSE LLP
`Eleven Times Square
`New York, NY 10036
`
`
`PROSKAUER ROSE LLP
`/Anthony C. Coles, Reg. No. 34,139/
`Anthony C. Coles, Reg. No. 34,139
`
`/John C. Stellabotte, Reg. No. 47,969/
`John C. Stellabotte, Reg. No. 47,969
`Attorneys for Patent Owner
`
`
`
` 
`
`3
`
`

`

`CERTIFICATE OF SERVICE
`
`
`
`The undersigned certifies that PATENT OWNER’S REQUEST FOR
`ORAL ARGUMENT PURSUANT TO 37 C.F.R. § 42.70 was served on
`September 9, 2013 in its entirety electronically on:
`
`CPdocketMattson@oblon.com
`
`/John C. Stellabotte, Reg. No. 47,969 /
`John C. Stellabotte, Reg. No. 47,969
`
`
`
` 
`4748/51020-001 current/38565971v1
`
`4
`
`

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